New Dodd-Frank Investment Adviser Rules: How Will They Impact Your Firm?
The SEC continues to adopt new rules for implementing the Dodd-Frank Act that affect investment advisers.
This session will catalogue those rules and highlight the key requirements of several rules including:
1) Mid-sized advisers:
Under the adopted rules for increased threshold for SEC registration, all advisers registered with the SEC on January 1, 2012, must file an amendment to Form ADV no later than March 30, 2012. Advisers will be required to respond to new items in Form ADV to identify “mid-sized advisers” no longer eligible to remain registered with the SEC. Any adviser no longer eligible for SEC registration will have to withdraw its registration no later than June 28, 2012. Effective July 21, 2011, new advisers applying for registration with the SEC with between $25 and $100 million in AUM are prohibited from registering with the SEC and must register with the appropriate state securities authority. This session will provide a detailed analysis of the implementation of the new “mid-sized adviser” category and what it portends for advisers that fall into this category.
2) Form ADV changes:
The new rules also have created a different methodology for calculating assets under management and a host of amendments to Form ADV that require advisers to provide additional information about private funds advised by the adviser; the adviser’s employees, clients and advisory activities; and other business activities and financial industry affiliations of the adviser.
3) Recent developments in political contributions
New “pay to play” rule amendments and FAQs will also be addressed.
4) Private Funds
There are now three new exemptions from SEC registration: private fund advisers, venture capital funds and foreign private advisers. Timing for new registrants varies but generally all advisers that are unable to rely on an exemption after Dodd-Frank will need to be registered by March 30, 2012.The SEC has adopted rules that would require SEC-registered investment advisers that advise private funds to provide specific information about the private funds they advise on a new Form PF. The Financial Stability Oversight Committee would use this information to monitor systemic risk.
These and other new regulatory reform rules will be fully explained by our compliance experts.
After attending this course, attendees should be able to:
- Survey the changes and determine which new rules apply to your firm.
- Define the basic parameters of the “mid-sized adviser” registration threshold and other new prohibitions on SEC registration and their impact on certain investment advisers.
- Pinpoint key changes in determining assets under management.
- List the changes to Form ADV reporting requirements for both registered and “exempt reporting” investment advisers.
- Apply amendments to the “pay to play” rule.
For Whom: Chief Compliance Officers, Internal auditors, Compliance Staff at all levels, Marketing personnel, Legal counsel and Management
Suggested Skill Level: Intermediate
Instructional Method: Group-Internet-Based
Pre-requisites for participation: No pre-requisites are required.
Advance Preparation: None
Continuing Education Credits:
NRS Continuing Education Guide
Recommended CPE Credit: 2 in the Regulatory Ethics field of study